Your Compliance Department is there to guide and protect the Bank and the Business Lines against compliance risks that could jeopardize not only the product or the Business Line, but the organization as a whole.
Guest post by Melanie Smith, CRCM, Compliance Advisory Officer
You’re driving to a concert with your friend. You’re running behind and you both spent a lot of money on the tickets and don’t want to be late. So, of course, you are speeding down the freeway. You were initially going 5 MPH over, but after looking at the clock and becoming more worried, you increase your speed from 60 MPH to 83 MPH. The speed limit is 55 MPH.
Your friend looks over at your speedometer and tells you that he knows that cops shoot radar under the bridge you are approaching. You don’t drive on this part of town very often, but shrug it off because your friend is always conservative with traffic laws. “Oh we will be fine” you say as you continue speeding. “I don’t want be late. These tickets cost a fortune!” Your friend replies, “We will be even later if we get pulled over for speeding. Plus you will get a pricey ticket. Please slow down. They have people pulled over all the time.”
Do you listen to your friend? Are you irritated that your friend warned you about the speed trap or appreciative? If you get pulled over and find out later that your friend knew of the speed trap but didn’t say anything, are you angry with him? Is the reward of not being 5 minutes late worth the risk of a $200 ticket and being significantly late, maybe even missing the entire opening act?
In case you haven’t guessed where I am going with this; you are the Business Line of the Bank and your friend is your Compliance Officer in this analogy. I want to illustrate the relationship between Compliance Departments and the Banks’ Business Lines in this manner because Compliance Officers and Departments get a bad rap. We are traditionally viewed as the department of “NO;” trying to do everything we can to make certain the Business Line can’t operate efficiently or make a profit.
This couldn’t be farther from the truth. Your Compliance Department is there to guide and protect the Bank and the Business Lines against compliance risks that could jeopardize not only the product or the Business Line, but the organization as a whole. Millions of dollars in civil monetary penalties and consumer restitution doesn’t help anyone’s bottom line, not to mention the lasting effect damage to the bank’s reputation can have to profitability (just ask Wells Fargo).
Your Compliance Department WANTS the Business Lines to make money. We WANT our Banks to grow. Growth and profitability provides us with job security and comfortable salaries. We just want to operate within the letter of the law so that you don’t get pulled over by the actual police (Examiners and /or the CFPB.) So when we ask you to slow down, please don’t take offense. We didn’t set the speed limit and we don’t want to be late to the concert either.
These opinions are those of the author and do not necessarily reflect the opinions of her employer.
About the Author
Melanie Smith is a Compliance Officer at an OCC-regulated bank with over $20B in assets and obtained the designation of Certified Regulatory Compliance Manager (CRCM) in June 2016. She got her start in Compliance at a community bank in June 2013, where she learned to manage compliance with a multitude of regulations, including Fair Lending, which is her passion.